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Can a certificate of release of federal tax lien - form 668(Z) - be superseded by a new lien for the same tax year?

Chicago, IL |
Filed under: Tax lien Lien

If someone gets one of these notices, does it mean that there is no more tax for that tax year? Or is it possible for the IRS to redetermine a liability for tax deficiencies, additions to tax, or penalties for that tax year at a later date? The form has a field for "last day for re-filing", which is shown as Jan 1, 2018.

Thank you to everyone who answered.

Attorney Answers 4


  1. If additional funds are owed, a new lien can be filed.


  2. This question is probably more complicated than it first appears. There are a number of factual issues here that clearly need to be addressed. A "release" of lien typically means the liability for which the lien issued is paid or there is a zero balance - a withdrawal means there was some other reason to get rid of the lien. Depending on a number of factors new taxes or penalties could be assessed....just don't know enough.

    This is not legal advice nor intended to create an attorney-client relationship. The information provided here is informational in nature only. This attorney may not be licensed in the jurisdiction which you have a question about so the answer could be only general in nature.


  3. I couldn't really give you an answer without seeing all the relevant documentation.

    This posting is for informational purposes only. It is not legal advice, nor does it establish an attorney-client relationship. For more information, please visit www.justinelderlaw.com.


  4. The chances of the IRS filing a new lien for the same year after it has filed a release of lien are very slim. This is true because the IRS generally has only three years from the filing of a tax return to make a tax assessment, unless fraud is involved, there has been an understatement in tax of 25% or more, or the taxpayer has failed to file a return. Thus, you probably do not have to worry about another lien being filed against you for that year.

    The answer to this question does not establish an attorney-client relationship. Moreover, this attorney is licensed to practiced law ONLY in the State of California. Answers to questions from users in other jurisdictions or states are meant to provide only general information. Users should contact a local attorney in their jurisdiction or state to address their specific tax issue.

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